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Notre Dame Law Review

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This Article is divided into three Parts. The first Part is devotedto an example demonstrating that, while double taxation may be gratuitous in a purely domestic context, it invariably becomes necessary in a multinational context. The second Part formalizes and generalizes the example, and concludes that double taxation is not only necessary in a multinational context, but also in any multi-period domestic context. The third Part contains a few policy prescriptions that, I fervently hope, will guide future administrations.

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